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I:\MEPC\48\WP\12a1.doc MED JHK mb For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies. INTERNATIONAL MARITIME ORGANIZATION IMO E MARINE ENVIRONMENT PROTECTION COMMITTEE 48th session Agenda item 3 MEPC 48/WP.12/Add.1 9 October 2002 Original: ENGLISH RECYCLING OF SHIPS Development of guidelines on recycling of ships Report of the Working Group (continued) This addendum contains the draft IMO Guidelines on Ship Recycling. The text in square brackets represents changes/new text developed by the Working Group. ***

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For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

INTERNATIONAL MARITIME ORGANIZATION

IMO

E

MARINE ENVIRONMENT PROTECTION COMMITTEE 48th session Agenda item 3

MEPC 48/WP.12/Add.1 9 October 2002 Original: ENGLISH

RECYCLING OF SHIPS

Development of guidelines on recycling of ships

Report of the Working Group

(continued)

This addendum contains the draft IMO Guidelines on Ship Recycling. The text in square brackets represents changes/new text developed by the Working Group.

***

MEPC 48/WP.12/Add.1

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ANNEX

DRAFT IMO GUIDELINES ON SHIP RECYCLING

PREAMBLE [These guidelines have been developed to give guidance to all stakeholders in the ship recycling process. This includes administrations of shipbuilding and maritime equipment supplying countries, flag, port and recycling States, as well as intergovernmental organizations and commercial bodies such as shipowners, ship builders, repairers and recycling yards. Additional stakeholders include workers, local communities, environmental and labour bodies. All ships, at some stage, reach the end of their useful life. The life cycle for most ships, from �cradle to grave� or �makers to breakers�, gives a 20-25 year life span of operation. In 2001, the OECD recently noted an increasing casualty rate for older ships remaining in operation, especially for bulk ships and tankers. The steady withdrawal of older ships and their replacement by new tonnage, therefore, is a natural commercial process which provides the opportunity for the introduction of safer and more environmentally friendly designs, greater operating efficiency and a general reduction in marine risk. In general, ships are recycled conforming to one of the basic principles of sustainable development. There are few alternatives to recycling ships � lay-up only postpones the issue; there is only a limited opportunity to convert ships for other uses such as storage facilities, breakwaters or tourist attractions; scuttling, although strictly controlled by the London Convention, gives no opportunity for the steel and other materials and equipment in a ship to be re-used and does not provide the owner with any final value on the ship. So, recycling is, generally, the best option for all time-expired tonnage. Furthermore, demand for ship recycling is expected to rise in the near future as ships, particularly tankers, which do not conform to the new international requirements set by the MARPOL Convention meet the end of their commercial lives. While the principle of ship recycling may be sound, the working practices and environmental standards in the yards often leave much to be desired. Although responsibility for conditions in the yards has to lie with the countries in which they are situated, other stakeholders have different roles to contribute towards minimising potential problems in the yards and are encouraged to fulfil them. These guidelines were developed to that end. IMO has developed these guidelines to provide guidance and standards for the [final] preparations of ships destined for recycling. These guidelines were prepared to complement other international guidelines addressing this issue; notably one set from the International Labour Office addressing working conditions at the yards and another set from the Basel Convention on the Transboundary Movement of Hazardous Wastes and their Disposal addressing environmental considerations at ship recycling facilities. As well, the provisions of other international instruments, or work of their governing bodies, may be applicable to ship recycling activities addressed by these guidelines, such as the Montreal Protocol on CFCs, the POPs Convention, or the London Convention 1972 on dumping at sea.

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1 General 1.1 Application These guidelines were developed considering key principles to (1) provide practical solutions to the preparations of ships; (2) foster inter-agency cooperation; and (3) encourage the importance of recycling as the key sustainable means to manage ships at the end of their commercial lives. For the purpose of these guidelines: [Disposal or removal refers to the removal of materials from ships in preparation for recycling and is understood that such material would then need to be managed in an environmentally responsible manner consistent with local regulations and international controls. Flag States refer to countries where ships are registered, particularly the State of registry at the end of a ship�s commercial life. Hazardous material refers to materials considered to be dangerous or pose harm to human health or the environment within the meaning of the IMDG Code, the Basel Convention, or other international authority or instrument. Recycling States refer to countries were ship recycling, as described above, occurs. Ship refers to the definition of a ship under Article 2(4) of MARPOL 73 which states: Ship means a vessel of any type whatsoever operating in the marine environment and includes hydrofoil boats, air-cushion vehicles, submersibles, floating craft and fixed or floating platforms. For the purpose of these guidelines on ship recycling, the term �ship� would also include both ships operating under their power and ships that have been stripped of equipment and would be towed. The commercial life of a ship refers to the time where it is operating and capable of performing its intended function to generate income for the owners. Shipowners refer to owners, operators, management companies and others who make decisions on the fate of ships at the end of their commercial lives. Ship Recycling refers to all associated operations including, mooring or beaching, dismantling, recovery of materials and reprocessing. 1.2 Activities undertaken by other organizations a) International Labour Organisation The ILO is concerned with shipbreaking and ship recycling where land-based workers in the industry are exposed to an extremely dangerous work environment with a high accident rate. All major occupational risks - chemical, physical, biological, ergonomic and psychosocial - are present. Although not drafted with ship dismantling in mind, a considerable number of existing ILO Conventions, Recommendations and Codes of Practice can be applied to deal with numerous occupational safety and health hazards and worker protection in shipbreaking operations. As a complement to the work undertaken in IMO and the Technical Working Group of the Basel Convention, ILO is preparing a "Technical Guide on a step-by-step approach towards safe

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shipbreaking". Their implementation will also depend on the effective application of the measures currently under discussion in other bodies. b) Secretariat and Parties to the Basel Convention Many materials carried on board of ships or contained in their structure will be classified as hazardous wastes, when destined for recycling or final disposal, under the Basel Convention. In order to assist countries which have or wish to establish facilities for ship dismantling, the Conference of the Parties to the Basel Convention instructed its Technical Working Group to prepare Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships. The Guidelines, approved by the Technical Working Group, provide information and recommendations on procedures, processes and practices that must be implemented to conform with the environmentally sound management obligations under the Convention. Once adopted by the Conference of the Parties, the Technical Guidelines provide for the minimum level of requirements for Parties, where dismantling of ships occur, to fulfil their obligations under the Convention. The Technical Guidelines are applicable to existing, as well as to new, ship dismantling facilities. They include principles for the environmentally sound management of ship dismantling, the good practice in environmental control procedures at ship-dismantling facilities, good practice in design, construction and operation of ship-dismantling facilities and how to achieve protection of the environment and human health. The Guidelines contain in Appendix B a list of hazardous wastes and substances under the Basel Convention that are on board or inherent in the ship structure when the vessel arrives at a dismantling site. The Technical Guidelines prepared under the auspices of the Basel Convention are complementary to those prepared by IMO and ILO, and represent a substantial contribution to addressing the life-cycle management of end-of-life equipment. The successful and effective implementation of the recommendations of the Basel Convention Technical Guidelines requires a proper and adequate preparation of ships for dismantling and an improvement in having more environmentally friendly ships through the minimization of hazardous substances in the building process.] c) Shipowners i) Industry Code of Practice on Ship Recycling The Industry Working Party on Ship Recycling was established under the co-ordination of ICS in February 1999 in response to growing concerns expressed by governments, environmental groups and the industry itself regarding: • the legal position with respect to potentially hazardous substances on vessels sold for

recycling; • the working conditions and safety provisions for workers in recycling yards; and • environmental controls at recycling yards.

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The Industry Working Party comprises representatives from: Baltic and International Maritime Council (BIMCO) International Association of Dry Cargo Shipowners (INTERCARGO) International Association of Independent Tanker Owners (INTERTANKO) International Chamber of Shipping (ICS) International Tanker Owners Pollution Federation (ITOPF) International Transport Workers� Federation (ITF) Oil Companies� International Marine Forum (OCIMF) The Industry Group, recognising the concerns of various parties, has developed a Code of Practice, outlining a series of recommendations which would constitute �good practice� in respect of ships destined for recycling. This Code of Practice is now available and has been circulated as MEPC 47/3/2. It deals primarily with issues which shipowners themselves can reasonably be expected to address. MEPC 47 welcomed the initiative taken by the shipping industry in producing the Code of Practice on Ship Recycling to the extent that, at least initially, these guidelines would be based upon it. ii) Contract covering the sale of a ship for recycling The Baltic & International Maritime Council (BIMCO) have revised their standard contract covering the sale of ships for recycling, DEMOLISHCON, to incorporate, in the standard terms and conditions, reference to the Industry Code of Practice. 1.3 Identification of hazardous substances The principal components of a ship (e.g., steel, iron, aluminium) are not an overriding concern from the standpoint of human health or marine pollution. However, there are a number of potential sources of pollution that should be addressed when considering recycling options. The main sources of hazardous substances typical to ships at the point of recycling are cargo and operational residues such as • fuel, lubricants, and coolants; • floatable materials (e.g., plastics, styrofoam insulation); • Materials possibly containing PCBs such as wiring insulation; • sludges; • harmful aquatic organisms in ballast water; and, currently (on older ships); and • asbestos used as insulation material and accommodation panelling. Items on ships that may potentially contain substances of concern include: • electrical equipment (e.g., transformers, batteries, accumulators); • coolers; • scrubbers; • separators;

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• heat exchangers; • storage facilities for production and other chemicals; • tanks, diesel tanks including bulk storage tanks; • stored solvents, and other chemical stocks; • paints; • sacrificial anodes; • fire extinguishing and fire fighting equipment; • piping, valves and fittings; • pumps and compressors; • engines and generators; • oil sumps; • hydraulic systems; and • light fittings and fixtures. In identifying potentially hazardous materials on board ships, there are two key lists to consider for guidance: the list of hazardous wastes from the Basel Convention, and the inventory of hazardous substances from the Industry Code of Practice. Both lists are presented in Appendices 1 and 2 to these Guidelines for reference. 2 �Green passport� 2.1 The �Green Passport� The concept of a �Green Passport� for ships has been promoted. It is envisaged that this document, containing an inventory of all materials potentially hazardous to human health or the environment, utilised in the construction of a ship, would accompany the ship throughout its working life. The document, produced by the shipyard at the construction stage and passed to the purchaser of the vessel, would be in a format to record any subsequent changes in materials or equipment. Successive owners of the ship would maintain the accuracy of the Green Passport and incorporate into it all relevant design and equipment changes, with the final owner delivering it, with the vessel, to the recycling yard. i) Applicability of the �Green Passport� Although the requirement of a green passport applies primarily to new ships, its compilation and use is recommended for existing ships.

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ii) Contents of �Green Passport�

[GREEN PASSPORT FOR SHIP RECYCLING (According to the IMO Guidelines on Ship Recycling)

Ship Name on New-building Delivery: Shipyard Name and Address: Date of Ship Delivery: IMO Number: Notes:

1) This document contains an inventory of all materials potentially hazardous to human health or the environment, utilised in the construction of the ship, its equipment and systems, as listed in the Annexes of the document.

2) This document shall accompany the ship throughout its working life and be handed over

to the recycling yard when finally the ship is sent for demolishing.

3) This document is to be initially produced by the new-building shipyard at the construction stage and delivered with the new-building ship to its first owner.

4) This document is to be passed on to the successive owners of the ship after recording any

changes in the materials, quantities and locations as listed in the Annexes.

5) Successive owners of the ship shall maintain the accuracy of the document and incorporate into it all relevant design and equipment changes as well as changes in materials, quantities and locations in the construction, equipment and systems.

6) For the Final Voyage, the inventory of hazardous materials (spares, stores and cargo and

operational residues) with their quantities and locations shall be attached to this document while handing over to the recycling yard.

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No. Details On New-

building Delivery

Changes on date ���..

Changes on date ����

1 Flag State 2 Ship Name 3 Port of Registry 4 Official No. 5 Call Sign 6 Ship owner Name 7 Ship owner address 8 Ship type and category 9 Classification Society and Notations 10 LOA 11 Breadth(Moulded) 12 Depth(Moulded) 13 Gross Tonnage 14 Lightweight 15 Deadweight 16 Main Engine(s) Type & KW 17 Fuels used onboard 18 Change effected on Annexes 19 Signature of owner�s Representative 20 Endorsement by Competent Authority N.B. Further annexes to be developed.] 3 New ships (see also section 2.1) The following measures are appropriate for all [ships as defined] by MARPOL [73/78] and are equally appropriate for other floating structures (e.g. semi-submersible drilling rigs). 3.1 Minimization of hazardous substances used in the construction of new ships and

their equipment Some of the problems associated with ship recycling might be addressed at the design and building stage, not only in relation to the ships themselves but also in respect of ships� equipment. The first issue is to identify any potentially hazardous materials which might be incorporated, as a matter of routine, in the structure of vessels and their equipment (see Appendices 1 and 2) and, where relevant, look for less hazardous alternatives. The initial stages might include an evaluation of: a) the type, amount and potential hazard of materials utilised and their location on board a

ship; b) the activities expected for operation of the ship and any potentially hazardous wastes

which might be generated; and

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c) the feasibility of addressing the potential for hazardous waste by considering:

• product reformulation; • cleaner production technologies; • process modification; • input substitution; and • on-site, closed-loop recycling.

Naval architects and shipbuilders should be encouraged to take due account of the ship�s ultimate disposal when designing and constructing a ship, by • using materials which can be safely recycled; • minimising the use of materials known to be potentially hazardous to health and the

environment; • [limiting the use of sandwich panels and other such materials that are difficult to separate

into their specific individual substances or components]; and • taking measures to facilitate the removal of such materials. In general terms, if opportunities exist for end-of-life waste minimisation or prevention at source, a ship or equipment designer or operator could formulate and implement a strategy to include specific waste reduction targets and provision for further waste prevention audits. [Administrations of flag States and ship building States should have a role in limiting the use of hazardous materials in the construction of ships and Administrations of ship building States should have a role in encouraging research into the use of less potentially hazardous materials in the construction of ships. Administrations of ship building States should also encourage construction techniques that optimize ships for recycling.] Materials banned by governments as listed under Appendix 5 [to be developed] should not be used in the construction, refit and repair of ship. 3.2 Design of ships and ships' equipment to facilitate recycling and to facilitate removal

of hazardous materials during, or at the end of a ship's life cycle Suppliers of marine equipment which contain hazardous substances, such as Halon, should be encouraged to design them so as to facilitate the safe removal of those substances, or give advice as to how such substances can be safely removed, at the end of the working life of the equipment. 3.3 Establishment and maintenance of an Inventory of Hazardous Materials, and other

materials that are of concern for recycling operations on board ships throughout the life cycle of the ship

In respect of new ships, equipment suppliers, classification societies and administrations should consider taking measures to facilitate an accurate inventory of hazardous materials used on board ships.

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4 Existing ships 4.1 Establishment of an Inventory of Hazardous Materials, and other materials that are

of concern for recycling operations on board ships Shipowners should be encouraged to initiate a programme to identify and record, as far as is practicable, on each of their existing ships, potentially hazardous materials (see Appendices 1 and 2) inherent in their construction or used in their equipment and machinery. Such a record should be passed to any subsequent owners of the vessel. 4.2 Minimization of hazardous substances during maintenance or major conversions Once a list of potentially hazardous materials which might be found on board ships, or inherent in their structure, is available, shipowners are encouraged to make every effort to minimize the amount of potentially hazardous materials on board the ship, including those carried as stores, during routine or major maintenance or major conversions. 4.3 Maintenance of inventory Shipowners should be encouraged to maintain and update [the inventory] with any structural or equipment changes made during the life of the vessel. [4.3.A How to maintain ownership responsibility towards the end of the ship's life until responsibility is taken over by the recycling yard At the end of a ship's life the shipowner is responsible for delivery of the ship as described in the contract, including all the documents in accordance with the guidelines (inventory, etc.). The shipowner is responsible for the preparation of the ship in order to ease recycling by the yard. Furthermore, the shipowner explicits his responsibility for the environmentally sound removal of the hazardous materials and wastes on board the ship or in the structure. This responsibility is described in the contract between the yard and the owner and states that parties agree that all the hazardous materials will be removed before the steel structure is scrapped. The shipowner reserves the right to monitor the process and procedures during demolition and dismantling, e.g. by inspection of a surveyor on behalf of the shipowner. If completion by the yard is as agreed in the contract and confirmed by the surveyor.............At the end of the recycling process another incentive is paid upon receipt of a deletion certificate by the shipowner.] 4.4 Preparation of ships for recycling [The preparation of a ship for recycling should address occupational safety and health, and environmental issues as well as the safe operation of the ship on its final voyage to the recycling facility. Conditions that may threaten worker safety at the recycling facility should, to the extent practicable, be identified by the shipowner and either be rectified or reported to the recycling facility to ensure that appropriate safety precautions are taken. The shipowner should use its best efforts to have its ships brought to recycling facilities that are capable of implementing such precautions.] Similarly, any materials with the potential to harm human health or the marine environment should either be removed from the vessel or minimized in amount and location and reported to

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the recycling facility to ensure that suitable arrangements are made for their reclamation, recycling or disposal. The preparation of the ship for recycling is, to a large extent, dependent on what a recycling yard is capable of and what is allowed by the national administration. The ideal is for the yard to be able to recycle the whole ship in a responsible way [and that shipowners see to it that their ships are recycled in yards which are capable of this in accordance with international regulations, e.g. guidelines developed under the Basel Convention]. Waste management and the disposal of the waste remains a key issue. There is no doubt that the preparation of the ship for recycling can be done most effectively when the ship is already at the recycling yard and shipowners should be encouraged to work with the yard in determining the extent of pre-recycling work that is desirable. The development and implementation of a recycling plan can ensure that a ship has been prepared to the maximum extent possible prior to its recycling. The plan should be developed in consultation between the owner or operator of the ship and the recycling yard, taking into account the potential hazards which may arise during the recycling operation, the legal requirements and international commitments of the recycling state and the facilities available at the relevant recycling yard in terms of materials handling and the disposal of any wastes generated during the recycling process. The plan could use the Inventory of Hazardous Materials as a starting point. The purpose of this plan is to ensure that wastes potentially contributing to pollution of the marine environment, and any potential hazards to worker health and safety, can be properly identified and handled. The recycling plan should take into account inter alia: i) details of the ship�s operational equipment and potential sources, amounts and relative hazards of potential contaminants (including chemical and biological) that may be released to the environment as indicated by the Inventory; and ii) potential hazards to worker safety which may arise during the recycling operation. In addition, the last operational owner of a ship should:- a) seek to ensure that the ship reaches the recycling yard with the minimum quantities of fuel, diesel, lubricating, hydraulic and other oils and chemicals consistent with the safe operation of the vessel; b) [in connection with the delivery of a ship, provide or arrange for a gas-free, hot work safe certification for cargo tanks, pump rooms, and coffer dams issued by the relevant authorities. It should be recognized that any such certification is valid only at the time it is issued;] c) make every effort to ensure that an arrival inventory is prepared of asbestos, oils, toxic substances, ozone-depleting substances and all other potentially hazardous materials, including those inherent in the structure of the vessel or used as coatings on the vessel, those contained in machinery, pipelines or cylinders or carried as stores, or accumulations of operational residues, to be handed over, against receipt, to the recycling yard (a recommended inventory form is attached

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at Appendix 4). (It is accepted that different types of ships may require a specific type of inventory.); d) ensure that any compartments on the ship which may contain an oxygen-deficient atmosphere are clearly marked as such, and that the yard is duly notified of these and other hazardous enclosed spaces and how to test them; e) take measures to facilitate the controlled drainage, by the recycling yard, of potentially harmful liquids from the ship; f) consider the environmental, health and safety benefits of towing a vessel to the yard, fully cleaned and certified to be free of oil, tank residues and other potentially hazardous and toxic material; and g) consider the possibility, prior to handing over the vessel for recycling, of:

• the removal and safe disposal of asbestos prior to arrival or, alternatively, the clear marking of any Asbestos Containing Materials (ACMs) or Presumed Asbestos Containing Materials (PACMs);

• the discharge of halon to an approved facility and the use of portable and

returnable fire-fighting equipment for the final voyage to the recycling site; and • providing advice on the nature of any hazardous materials on board, as indicated

in the inventory of hazardous materials.

Those entering into a contract of sale of a vessel to a recycling yard should be encouraged to consider the working practices and facilities in the ship recycling yard(s) in question, including; • their ability to handle safely, and dispose of properly, any potentially hazardous or

environmentally harmful products that may be present in the ship such as asbestos, PCBs, halons, petroleum products and other residues;

• the provision of appropriate and sufficient personal protection and safety equipment; and • other information such as safety records, training programmes for workers and

assessment of the work quality. 5 Stakeholders� Roles 5.1 Flag State The role of the flag State covers the whole operational life of a ship (including its ultimate voyage) and, during that life it should ensure that the ship complies with all IMO Conventions for as long as the ship is operational. However, to take into account the final voyage of a ship, the flag State should recommend and encourage the completion of an inventory of potentially hazardous materials on board to be handed to the recycling yard on delivery of the ship.

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The flag States should encourage their industry to implement the Guidelines adopted by IMO. 5.1.1 Establishment of criteria for �ready for recycling� conditions [Flag States should establish criteria to declare a ship "ready for recycling". The basis for such criteria would be that the work to prepare a ship for recycling, set out in section 4.4 of these Guidelines, has been completed, which would also include final inventory of hazardous materials, set out in section XX, at the end of the ship's life.] 5.1.2 Implementation Flag States should: • encourage the widespread use of the IMO guidelines within the industry; • urge the use of a ship recycling sales contract, such as [DEMOLISHCON] the BIMCO

[standard contract], which ensures that full account is taken of all relevant environmental, health and safety considerations; and

• co-operate with recycling States to facilitate the implementation of the guidelines 5.2 Port State [The port State assumes a role after the signing of the port State control MoU and it functions as a supplement to flag State control when it executes port State control.] 5.2.1 Establishment of port State control routines for ships destined for recycling The only port State in a position to control issues related to a ship destined for recycling is that of the final place of arrival of an operational vessel i.e. the port where the recycling operation is to take place (see �Recycling State� below) or the port where a vessel, because of the measures taken to prepare it for recycling, it is rendered non-operational and is intended to be towed to the recycling yard. Until then, all port state control routines and obligations (for example in respect of the provision of ship�s waste reception facilities) apply. [Ships destined for recycling would still be subject to current port State control procedures, as any other ship, in accordance with applicable international regulations. Co-ordination between the port State and the flag State is encouraged to ensure the ship meets all relevant IMO requirements, and any other applicable requirements.] 5.2.2 Implementation Port States should:

• encourage the widespread use of IMO guidelines within the industry; • co-operate with flag States and recycling States to facilitate implementation of the

guidelines.

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5.3 Recycling State The role of the recycling State is to enforce international obligations and national legislation in respect of worker health and safety and the protection of the environment in the ship recycling industry, in particular, waste generated at a recycling site subject to disposal operations as identified in Annex IV (A) to the Basel Convention, taking into account those operations which may lead to resource recovery, recycling, reclamation, direct re-use or alternative uses identified in Annex IV (B) to the Basel Convention (attached at Appendix 1). The recycling State is also, of course, in a position to introduce national regulations in relation to the condition of ships purchased for recycling both at the time of purchase and at the time of delivery. In effect, the recycling State can lay down any conditions it considers necessary before a ship is accepted for recycling. The inventory of potentially hazardous materials which should be delivered to the recycling yard by the last operational owner of the vessel, should give the recycling State a good insight into the contents of the ship. The recycling State is in a position to check that any potentially hazardous wastes which might be generated during the recycling operation can be safely handled before it accepts the ship for recycling. After the ship has been accepted, the recycling State is responsible for monitoring the safe handling of any hazardous materials generated during the recycling process. 5.3.1 Establish or maintain adequate reception facilities for ship-generated wastes from

ships destined for ship recycling] Regulation 12.1 of Annex I to MARPOL 73/78 requires governments to provide reception facilities �at oil loading terminals, repair ports, and in other ports in which ships have oily residues to discharge� which are �adequate to meet the needs of the ships using them.� Regulation 12.2 (c) extends this to �all ports having ship repair yards or tank cleaning facilities.� While IMO Convention does not extend the requirement to the provision of such facilities at recycling places, Governments of recycling states should ensure that, in authorising a recycling activity, adequate reception facilities are in place. The IMO Manual for Port Reception Facilities provides detailed guidance to manage ship-generated wastes. The Technical Guidelines for the Environmentally Sound Management of Ship Dismantling Facilities under development by the Parties to the Basel Convention may also provide some guidance. 5.3.2 Establishment of routines for control of ships delivered for recycling All recycling States can, in their national legislation, lay down the conditions under which ships may be accepted into their state as imports for recycling and, equally, define and enforce appropriate worker health and safety requirements. All recycling States are urged to introduce, if they have not already done so, and enforce legislation which requires that all ships destined for recycling are delivered to the recycling yard in a gas-free condition, with all tanks, except the necessary fuel tanks for the final voyage, cleaned and certified to full hot work and entry standards.

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Those administrations with responsibilities for recycling yards should consider introducing a �Certificate of Approval� for yards meeting acceptable worker safety and environmental control standards. They should ensure that the handling and disposal of asbestos, oils and other hazardous substances, whether prior to the ship�s arrival at the recycling yard or subsequently, have been conducted in an acceptable manner. They should also urge those acting on behalf of recycling yards in purchasing vessels for recycling to utilise a standard ship recycling contract, such as the [DEMOLISHCON - the ]BIMCO [standard contract] document, which ensures that full account is taken of all relevant environmental, health and safety considerations. The recycling yard should be required to check every ship before it accepts it. This check should ensure that the actual condition of the ship is consistent with the purchase contract and that the inventory has been completed. At the moment the yard accepts the ownership of the ship for recycling, the responsibility for proper handling of any wastes generated lies with the yard. 5.3.3 Implementation The recycling State itself has a responsibility for the introduction, implementation and enforcement of sound legislation concerning the recycling of ships. To this end, recycling states are urged to examine, and where necessary adopt into national legislation, any applicable internationally developed conventions, recommendations and guidance relevant to the ship recycling industry such as those produced by the International Labour Organisation (ILO). The recycling State should also be prepared to give support to their yards in the decision to accept or not to accept a ship for recycling. The yards themselves are responsible for handling the vessel and the recycling operation in compliance with national legislation. 5.4 The Shipping Industry (Shipowning/Ship operating) A lot of problems with ship recycling can be solved by good co-operation between the shipowner and the recycling yard, before and during the recycling operation. Shipowners are urged to develop this co-operation. The shipping industry is encouraged to continue development of the �Code of Good Practice� covering inter alia ship recycling operations (which includes encouraging owners to prepare and hand over to the recycling yard, a pre-recycling inventory), seeking endorsement of and comments on its work from MEPC at regular intervals in the future and working with Classification Societies in improving plans to decommission ships in a safe and environmentally sound manner. 5.5 Brokers and Intermediate (cash) buyers [The sale and purchase of a ship takes place several times during its life and this is generally conducted between the brokers acting on behalf of the seller and the buyer. When a ship is destined finally for sale to a ship recycling yard, the procedure is similar. However, the sale of a ship to a recycling yard has considerable commercial risk due to wide fluctuations in the market over a short time. To avoid the commercial risk, the shipowner sells

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his ship through a broker who specializes in obtaining ships for recycling to an intermediate or cash buyer who is also a specialist in this business and has knowledge and contacts normally not possessed by the shipowner. Thus, the seller's broker and, more so, the cash buyer virtually control the sale of a ship to a recycling yard. The cash buyer, by investing only a small percentage of the ship's price, holds the ship under his control until he selects a recycling yard to his advantage, normally at a later date. Hence, his role in obtaining details of the ship purchased and passing these details to the recycling yard is vital. Under these circumstances, the shipowner has no role to play in the selection of the ship recycling yard. The chain of communications between the final operator (owner) who sells the ship to a recycling yard is a long one involving several parties, but mostly devoid of transparency. These guidelines are intended to bring in accountability and transparency between the chain of communications.] 5.6 Environmental Groups Enviromental groups and others are encouraged to continue to monitor the issues associated with ship recycling and report on ship recycling issues in a responsible manner.

5.7 The Ship Recycling Industry The ship recycling industry itself should clearly be included in any list of �stakeholders� although standards of operation in those shore-based industries involved in ship recycling do not fall within the remit of IMO. However, they have a role in establishing control standards in their yards which contribute towards ensuring the safe and environmentally friendly disposal of time-expired vessels. The industry is encouraged to: • take due note of available technical guidance on ship recycling such as the guidelines

developed by Det Norske Veritas (DNV) or the US Environmental Protection Agency (EPA);

• develop a code of practice appropriate to that industry, as guidance on work practices in

relation to shore based activities in recycling yards to ensure acceptable environmental, safety and health standards and to monitor its application;

• encourage appropriate international bodies to endorse any ship recycling industry code of

practice; • encourage recycling yards to make publicly available details regarding the chosen method

for the safe handling of asbestos, PCBs and PABs, halon/freon, oily residues and hazardous atmospheres in enclosed spaces; and

• establish a structure to improve the quality system of the yards by implementing measures

as proposed by IMO, ILO and Basel and improving the quality of the personnel and of the equipment. Yards must be encouraged to work with proper procedures and have adequate waste management systems.

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5.8 Technical assistance Ship recycling, if conducted in an environmentally friendly and a safe manner, is a positive benefit to the overall environment and to specific national and local economies and represents the most viable method of disposing of the majority of time expired tonnage. Therefore, if the transfer of technology or aid funding is necessary to improve facilities and working practices in the yards, organizations or nation groupings with access to economic assistance funds are asked to look sympathetically at working together with the governments concerned with recycling on actual infrastructure projects. National or regional administrations are encouraged to work together with governments in ship recycling nations and other interested parties on projects involving the transfer of technology or aid funding to improve facilities and working practices in the yards. [The ILO should continue to develop programmes for raising awareness about improving working conditions at shipbreaking yards.] 5.9 The International Labour Organization [ILO will provide advice and guidance in helping to establish international standards for improving working conditions at shipbreaking sites. It would also assist administrations in establishing criteria by which yards might be ranked as meeting certain minimum requirements in order to obtain government "approval". The ILO should be encouraged to continue to develop and adopt a "Technical Guide on a step-by-step approach towards safe shipbreaking".] [5.10 The Basel Convention The Parties to the Basel Convention are committed to manage hazardous wastes, from whatever origin, in a manner to protect human health and the environment. 5.10.1 Environmentally sound dismantling of ships The Technical Guidelines prepared under the auspices of the Basel Convention are applicable to existing as well as new facilities for dismantling ships. The Guidelines make provisions for the proper and sound removal of hazardous wastes and substances, including their collection, sorting, or recycling and final disposal. The scope of the Guidelines covers the technical and procedural aspects of ship dismantling.] 5.10.2 Implementation The Parties to the Basel Convention should:

• [promote and implement the Basel Convention Technical Guidelines for the Environmentally Sound Management of the Full and Partial Dismantling of Ships;

• promote and encourage the minimization of hazardous materials in the

construction of ships;

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• co-operate with other stakeholders to aim at continuous improvement at the ship dismantling sites.]

5.11 The London Convention 5.12 Ship insurers

[.1 An extension of the 12 months' insurance (by owner) specifically to cover the voyage to the yard under own power. Insurers may ask for limited conditions and need a special survey to consider the voyage if outside normal operations, etc. Position of class also important; or

.2 a special voyage under own power (account buyer or seller or yard). Insurers will

require special survey of vessel condition and will cover on limited conditions (total loss only). Details of crew and any cargo needed. Flag details; or

.3 a special voyage in tow - need all as above but in addition details of tug towage

arrangements, etc. N.B. It is possible any specific IMO "guidelines" could be incorporated, when

relevant, into insurance policy terms.]

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[APPENDIX 1]

Basel Convention - Annex IV

DISPOSAL OPERATIONS A. OPERATIONS WHICH DO NOT LEAD TO THE POSSIBILITY OF RESOURCE

RECOVERY, RECYCLING, RECLAMATION, DIRECT RE-USE OR ALTERNATIVE USES

Section A encompasses all such disposal operations which occur in practice. D1 Deposit into or onto land, (e.g., landfill, etc.) D2 Land treatment, (e.g., biodegradation of liquid or sludgy discards in soils, etc.) D3 Deep injection, (e.g., injection of pumpable discards into wells, salt domes of naturally

occurring repositories, etc.) D4 Surface impoundment, (e.g., placement of liquid or sludge discards into pits, ponds or

lagoons, etc.) D5 Specially engineered landfill, (e.g., placement into lined discrete cells which are capped

and isolated from one another and the environment, etc.) D6 Release into a water body except seas/oceans D7 Release into seas/oceans including sea-bed insertion D8 Biological treatment not specified elsewhere in this Annex which results in final

compounds or mixtures which are discarded by means of any of the operations in Section A

D9 Physico chemical treatment not specified elsewhere in this Annex which results in final compounds or mixtures which are discarded by means of any of the operations in Section A, (e.g., evaporation, drying, calcination, neutralization, precipitation, etc.)

D10 Incineration on land D11 Incineration at sea D12 Permanent storage (e.g., emplacement of containers in a mine, etc.) D13 Blending or mixing prior to submission to any of the operations in Section A D14 Repackaging prior to submission to any of the operations in Section A D15 Storage pending any of the operations in Section A B. OPERATIONS WHICH MAY LEAD TO RESOURCE RECOVERY,

RECYCLING RECLAMATION, DIRECT RE-USE OR ALTERNATIVE USES Section B encompasses all such operations with respect to materials legally defined as or considered to be hazardous wastes and which otherwise would have been destined for operations included in Section A R1 Use as a fuel (other than in direct incineration) or other means to generate energy R2 Solvent reclamation/regeneration R3 Recycling/reclamation of organic substances which are not used as solvents R4 Recycling/reclamation of metals and metal compounds R5 Recycling/reclamation of other inorganic materials

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R6 Regeneration of acids or bases R7 Recovery of components used for pollution abatement R8 Recovery of components from catalysts R9 Used oil re-refining or other reuses of previously used oil R10 Land treatment resulting in benefit to agriculture or ecological improvement R11 Uses of residual materials obtained from any of the operations numbered R1-R10 R12 Exchange of wastes for submission to any of the operations numbered R1-R11 R13 Accumulation of material intended for any operation in Section B

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[APPENDIX 2] POTENTIALLY HAZARDOUS MATERIALS WHICH MAY BE ON BOARD VESSELS

DELIVERED TO RECYCLING YARDS (Industry Code of Practice on Ship Recycling) Note 1: This list is not definitive - see also EU Council Regulation No.259/93 Annexes II, III & IV. A. Operational Substances and Consumables 1. Cargo Residues including Slops 2. Dry tank Residues 3. Fuel oil, Diesel oil, Gas oil, Lubricating oil, Greases & Anti-seize Compounds 4. Hydraulic oil 5. Waste oils (contents of sludge tank) 6. Antifreeze fluids 7. Kerosene and White Spirit 8. Boiler and Feed Water Treatment Chemicals 9. Boiler and Feed Water Test Re-agents 10. De-ioniser Regenerating Chemicals 11. Evaporator Dosing and Descaling Acid 12. Domestic Water treatment Chemicals 13. Paints and Rust Stabilisers 14. Solvents and Thinners 15. Refrigerants (R12 or R22) 16. HALON 17. CO2 (in cylinders - engine room fire protection) 18. Acetylene, Propane and Butane 19. Hotel Services Cleaners 20. Lead-acid Batteries 21. Battery Electrolyte 22. PCB and / or PCT and / or PBB at levels of 50mg / kg or more 23. Mercury 24. Radio-active Material i.e. liquid level indicators 25. Miscellaneous Medicines 26. Insecticide Sprays 27. Miscellaneous Chemicals such as Alcohol, Methylated Spirits, Epoxy Resins, etc. 28. Plastics as covered by MARPOL 29. Raw and Treated Sewage B. Toxic Materials (as part of the ship�s structure) 1. Asbestos 2. Lead-based Paint Coatings on Ship�s Structure 3. Tin-based Anti-fouling Coatings on Ship�s Bottoms. 4. Others.

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[APPENDIX 3]

LISTS OF HAZARDOUS WASTES AND HAZARDOUS CHARACTERISTICS: RELEVANT ANNEXES TO THE BASEL CONVENTION ON THE CONTROL

OF TRANSBOUNDARY MOVEMENTS OF HAZARDOUS WASTES AND THEIR DISPOSAL ADOPTED BY THE CONFERENCE

OF THE PLENIPOTENTIARIES ON 22 MARCH 1989

CATEGORIES OF WASTES TO BE CONTROLLED

Waste Streams Y1 Clinical wastes from medical care in hospitals, medical centres and clinics Y2 Wastes from the production and preparation of pharmaceutical products Y3 Waste pharmaceuticals, drugs and medicines Y4 Wastes from the production, formulation and use of biocides and phytopharmaceuticals Y5 Wastes from the manufacture, formulation and use of wood preserving chemicals Y6 Wastes from the production, formulation and use of organic solvents Y7 Wastes from heat treatment and tempering operations containing cyanides Y8 Waste mineral oils unfit for their originally intended use Y9 Waste oils/water, hydrocarbons/water mixtures, emulsions Y10 Waste substances and articles containing or contaminated with polychlorinated biphenyls

(PCBs) and/or polychlorinated terphenyls (PCTs) and/or polybrominated biphenyls (PBBs)

Y11 Waste tarry residues arising from refining, distillation and any pyrolytic treatment Y12 Wastes from production, formulation and use of inks, dyes, pigments, paints, lacquers,

varnish Y13 Wastes from production, formulation and use of resins, latex, plasticizers, glues/adhesives Y14 Waste chemical substances arising from research and development or teaching activities

which are not identified and/or are new and whose effects on man and/or the environment are not known

Y15 Wastes of an explosive nature not subject to other legislation Y16 Wastes from production, formulation and use of photographic chemicals and processing

materials Y17 Wastes resulting from surface treatment of metals and plastics Y18 Residues arising from industrial waste disposal operations Wastes having as constituents: Y19 Metal carbonyls Y20 Beryllium; beryllium compounds Y21 Hexavalent chromium compounds Y22 Copper compounds Y23 Zinc compounds Y24 Arsenic; arsenic compounds Y25 Selenium; selenium compounds Y26 Cadmium; cadmium compounds Y27 Antimony; antimony compounds Y28 Tellurium; tellurium compounds

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Y29 Mercury; mercury compounds Y30 Thallium; thallium compounds Y31 Lead; lead compounds Y32 Inorganic fluorine compounds excluding calcium fluoride Y33 Inorganic cyanides Y34 Acidic solutions or acids in solid form Y35 Basic solutions or bases in solid form Y36 Asbestos (dust and fibres) Y37 Organic phosphorus compounds Y38 Organic cyanides Y39 Phenols; phenol compounds including chlorophenols Y40 Ethers Y41 Halogenated organic solvents Y42 Organic solvents excluding halogenated solvents Y43 Any congenor of polychlorinated dibenzo-furan Y44 Any congenor of polychlorinated dibenzo-p-dioxin Y45 Organohalogen compounds other than substances referred to in this Annex (e.g. Y39,

Y41, Y42, Y43, Y44)

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[APPENDIX 4]

INVENTORY OF POTENTIALLY HAZARDOUS MATERIALS ON BOARD

(Version August 2001) Name of Vessel GT Date of Inventory IMO Number DWT Date of Delivery Date of Build LDT Received by On behalf of

This form is intended for completion by the shipowner and/or his authorized representatives, including the master, on the vessel�s last voyage prior to being broken up. It provides an estimate of all known potentially hazardous or contaminating materials and substances which are thought to be on board the vessel, or inherent in its structure, or as an integral part of its machinery and/or equipment, at the point of sale. It should be handed over, together with any relevant attachments, by the shipowner or his representative to the purchaser or his representative on delivery of the vessel for breaking. The document may be supplemented, as appropriate, with more detailed information in respect of any of the categories included in this document. It is provided as guidance to the shipbreaking organization and his workforce and should not be regarded as a formal statement of precise quantities. It has no contractual force. Information on potentially hazardous materials inherent in the ship�s structure or its machinery and equipment, such as items listed in part 1 of the inventory, are likely to be supplied by the operating department ashore. However, information such as that related to residues (part 2 of the inventory) or consumables (part 3) cannot be completed until near the end of a vessel�s final voyage. This form has been developed by and is recommended for use by the following organizations: Baltic and International Maritime Council (BIMCO) International Association of Dry Cargo Shipowners (INTERCARGO) International Association of Independent Tanker Owners (INTERTANKO) International Chamber of Shipping (ICS) International Tanker Owners Pollution Federation (ITOPF) International Transport Workers� Federation (ITF) Oil Companies� International Marine Forum (OCIMF) with the assistance of the European Community Shipowners� Associations (ECSA) WHILST EVERY CARE HAS BEEN TAKEN TO ENSURE THAT THE INFORMATION PROVIDED IN THIS INVENTORY IS ACCURATE, UP-TO-DATE AND COMPLETE, NEITHER THE SHIPOWNER NOR ANY OF HIS REPRESENTATIVES ACCEPT ANY LIABILITY FOR ANY ERRORS OR OMISSIONS IN THE INVENTORY OR FOR ANY ACTS OR OMISSIONS OF ANY PERSON IN THE HANDLING, REMOVAL OR DISPOSAL OF THESE SUBSTANCES, WHETHER DONE IN RELIANCE ON THE

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INFORMATION IN THIS INVENTORY OR OTHERWISE. IT REMAINS THE RESPONSIBILITY OF EACH EMPLOYER TO PROVIDE APPROPRIATE TRAINING, GUIDANCE AND PERSONAL PROTECTIVE EQUIPMENT TO ITS EMPLOYEES TO ENSURE THE IDENTIFICATION, LOCATION, HANDLING AND DISPOSAL OF ALL MATERIALS ON BOARD THE VESSEL OR INHERENT IN ITS STRUCTURE, EQUIPMENT OR MACHINERY. IT IS STRESSED THAT THE INFORMATION PROVIDED IN THIS INVENTORY IS NOT A CONTRACTUAL STATEMENT OF PRECISE QUANTITIES OF RESIDUES AND MATERIALS ON BOARD. THE QUANTITIES GIVEN ARE ESTIMATES ONLY AND NO GUARANTEE OF THEIR ACCURACY IS EITHER GIVEN OR IMPLIED. (Copies of this inventory, suitable for completion, can be downloaded and printed at www.marisec.org/recycling.

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PART 1 - POTENTIALLY DANGEROUS MATERIALS IN THE SHIP�S STRUCTURE AND EQUIPMENT

1A. Asbestos (Note: All asbestos containing materials (ACMs) or presumed asbestos containing materials (PACMs) should be prominently labelled as such).

Type of Asbestos Materials (Board, Pipe lagging,

Contained)

Location Approximate Quantity

Engine Room/Machinery Rooms Steam supply piping and hangers (General) Steam exhaust piping and hangers (General) Relief & safety valves (General) Miscellaneous piping outer covering and

hangers (General) Water pipes and hangers (General) HP Turbine Insulation (General) Boiler drums & casings (General) Heaters, Tanks etc. (General) Other (General) Specific Machinery Locations e.g. Pump

Room, Boiler Room Accommodation Sanitary & Commissary spaces (General) Interior decks � including underlay

(General) Steam & exhaust pipes (General) Refrigeration pipes (General) Air conditioning ducts (General) Cable transits (General) External bulkheads (General) Internal bulkheads(General) External deckheads (General) Internal deckheads (General) Decks adjoining machinery spaces (General) Other (General) Specific accommodation locations Deck Steam supply piping (General) Exhaust piping (General) Tank cleaning piping (General) Stripping pump (General)

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Other (General) Specific deck locations Machinery Brake linings

Caution!! Asbestos containing material (ACM) may be found underneath materials that do not contain asbestos.

1B. Paint (on vessel�s structure) - Additives

Additive (Lead, Tin, Cadmium, Organotins (TBTs), Arsenic, Zinc,

Chromium, Strontium, Other)

Location

1C. Plastic Materials

Type Location Approximate Quantity

1D. Materials containing PCBs, PCTs, PBBs at levels of 50mg / kg or more

Material Location Approximate Quantity

1E. Gases sealed in ship�s equipment or machinery

Type Location Approximate Quantity

Refrigerants (R12/R22)

HALON CO2 Acetylene Propane Butane Oxygen Other (Specify)

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1F. Chemicals in ship�s equipment or machinery

Type Location Approximate Quantity

Anti-seize Compounds Engine Additives Antifreeze Fluids Kerosene White Spirit Boiler/Water Treatment

De-ioniser Regenerating

Evaporator Dosing and Descaling Acids

Paint/Rust Stabilisers Solvents/Thinners Chemical Refrigerants Battery Electrolyte Hotel Service Cleaners Other (Specify) 1G. Other Substances inherent in ship�s machinery, equipment or fittings

Type Location Approximate Quantity

Lubricating Oil Hydraulic Oil Lead Acid Batteries Alcohol Methylated Spirits Epoxy Resins Mercury Radioactive Materials Other (Specify) Part 1. completed by Position

Signature On behalf of (Company)

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PART 2 - OPERATIONALLY GENERATED WASTES 2A. Dry Tank Residues

Description of Residues Location Approximate Quantity

2B. Bulk (non-oily) waste

Type Location Approximate Quantity

Ballast Water Raw Sewage Treated Sewage Garbage (inc. plastics)

Debris Galley Wastes Other (Specify) 2C. Oily Waste/Oily Residues

Type Location Approximate Quantity

Cargo Residues Tank Scale Bunkers: Fuel Oil Diesel Oil Gas Oil Lubricating Oil Grease Hydraulic Oil Waste Oil (Sludge) Oily Water Oily/Contaminated Sludge

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Oily/Contaminated Rags

Other (Specify) Part 2. completed by Position

Signature On behalf of (Company)

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PART 3 - STORES 3A. Gases in store

Type No. and size of

Cylinders

Location Approximate Quantity

Refrigerants (R12/R22)

HALON CO2 Acetylene Propane Butane Oxygen Other (Specify) 3B. Chemicals in store

Type Location Approximate Quantity

Anti-seize Compounds Engine Additives Antifreeze Fluids Kerosene White Spirit Boiler/Water Treatment

De-ioniser Regenerating

Evaporator Dosing and Descaling Acids

Paint/Rust Stabilisers Solvents/Thinners Refrigerants Battery Electrolyte Hotel Service Cleaners Other (Specify) 3C. Other Packaged items in store

Type Location Approximate Quantity

Lubricating Oil Hydraulic Oil Lead Acid Batteries Medicines Insecticide Sprays Alcohol Methylated Spirits

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Epoxy Resins Paint Fire fighting clothing, equipment (e.g. blankets)

Other (Specify) Part 3 completed by Position

Signature On behalf of (Company)

WHILST EVERY CARE HAS BEEN TAKEN TO ENSURE THAT THE INFORMATION PROVIDED IN THIS INVENTORY IS ACCURATE, UP-TO-DATE AND COMPLETE, NEITHER THE SHIPOWNER NOR ANY OF HIS REPRESENTATIVES ACCEPT ANY LIABILITY FOR ANY ERRORS OR OMISSIONS IN THE INVENTORY OR FOR ANY ACTS OR OMISSIONS OF ANY PERSON IN THE HANDLING, REMOVAL OR DISPOSAL OF THESE SUBSTANCES, WHETHER DONE IN RELIANCE ON THE INFORMATION IN THIS INVENTORY OR OTHERWISE. IT REMAINS THE RESPONSIBILITY OF EACH EMPLOYER TO PROVIDE APPROPRIATE TRAINING, GUIDANCE AND PERSONAL PROTECTIVE EQUIPMENT TO ITS EMPLOYEES TO ENSURE THE IDENTIFICATION, LOCATION, HANDLING AND DISPOSAL OF ALL MATERIALS ON BOARD THE VESSEL OR INHERENT IN ITS STRUCTURE, EQUIPMENT OR MACHINERY. IT IS STRESSED THAT THE INFORMATION PROVIDED IN THIS INVENTORY IS NOT A CONTRACTUAL STATEMENT OF PRECISE QUANTITIES OF RESIDUES AND MATERIALS ON BOARD. THE QUANTITIES GIVEN ARE ESTIMATES ONLY AND NO GUARANTEE OF THEIR ACCURACY IS EITHER GIVEN OR IMPLIED.

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[APPENDIX 5] MATERIALS BANNED BY INTERNATIONAL CONVENTIONS FROM USE IN OR ON

SHIPS AND AS CONSTITUENTS OF SHIPS� EQUIPMENT

STOCKHOLM CONVENTION:

1. Aldrin 2. Chloordaan 3. Dieldrin 4. Eldrin 5. DDT 6. Hexachloorbenzene 7. Heptachloor 8. PCB and PCT 9. Dioxines and furans 10. �� To be completed later

MONTREAL PROTOCOL: 1. Halon 1211, 1301, 2406 2. CFC 11,12, 113, 114, 115 3. Trichloorethane 4. Methylbromide 5. �.. To be completed later Note: refilling of equipment with above-mentioned materials is forbidden

CONVENTION ON ANTI-FOULING SYSTEMS: 1. TBT 2. �.?

OTHER CONVENTIONS OR DIRECTIVES: 1. e.g. water directives 2. �.. To be completed later]

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[APPENDIX 6]

[PROPOSED TECHNICAL GUIDANCE FOR THE CLEAN-UP OF SHIPS DESTINED FOR RECYCLING

[Canada suggests the following;

The pollution prevention and cleanup techniques described below should be implemented for ships destined for recycling. Within technical and economic feasibility and taking into consideration the safety of workers, to the maximum extent, ships should be cleared of potential sources of hazardous materials indicated by the Inventory. Resulting wastes or materials should be re-used, recycled or disposed of in an environmentally sound manner. Among other measures. • materials remaining in tanks, piping, or holds should be removed from the ship to the

maximum extent possible (including, for example, fuel, lubricating oils, hydraulic fluids, cargoes and their residues, and grease). All drummed, tanked, or canned liquids or gaseous materials should be removed from the ship. All materials removed should be managed on land in an environmentally sound manner (e.g., recycling and, in certain cases, onshore incineration);

• removal of equipment containing liquid PCBs should be a priority; • remove any capacitors and transformers containing dielectric fluid from the ship to the

maximum extent possible; • if any part of the ship was used for storage of fuel or chemical stocks such as in tanks,

these areas shall be flushed and cleaned; • to prevent the release of substances that could cause harm to the marine environment, the

cleaning of tanks, pipes and other ship equipment and surfaces should be accomplished in an environmentally sound manner prior to recycling using appropriate techniques, such as high pressure washing techniques. The resulting wash water should be handled in an environmentally sound manner consistent with national or regional requirements to address potential pollutants; and

• as far as practicable, consideration should be given to avoiding the transfer of harmful

aquatic organisms in ballast water on board the ship. Detailed technical advice for further consideration on the clean up of ships destined for recycling is set out in Appendix 10 to these Guidelines. In addition to reducing pollution, measures to ensure worker safety at the recycling yard are a key component of the preparation of a ship destined for recycling. These measures include:

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• identifying and indicating the precise location of any area of the ship where there may be structural integrity problems, (e.g., collision damage) to avoid collapses and accidents;

• identifying and indicating the precise location of any area of the ship where there are critical support structures that should be dismantled in a way that avoids accidental structural collapse;

• ventilating fresh air through compartments to remove accumulated flammable gases as much as possible;

• identifying and indicating the precise location of any areas where there may be an accumulation of flammable gases (e.g., empty fuel tanks); and

• identifying and indicating the precise location of any area of the ship were there may be depleted oxygen levels or noxious vapours that may impair breathing.

The Working Group might be asked to discuss whether these issues raised by Canada are more relevant to working procedures at recycling yards rather than in IMO Guidelines.] 1. INTRODUCTION This document draws from a technical guidance document for the preparation of ships for disposal at sea in relatively shallow sites in Canadian marine waters. The guidance has been modified to consider ships destined for recycling and international requirements. 2. SUGGESTIONS FOR PLANNING WORK 2.1 The Pollution Prevention Plan The Pollution Prevention Plan, recommended in the Ship Recycling Guidelines, can be used to address both cost and cash flow issues. As well it can allow ship owners and operators to avoid repeated cleaning operations, and ensure certain components could be salvaged -subject to the sale contract for the ship. In general terms, salvage operations to remove useful components that contain hazardous materials should come first, taking care to minimize contamination with oils or other products that will have to be cleaned-up at a later date. Obligations of the sale contract for ship to the recycling facility may require certain equipment remain on board. Clean-up would typically follow any salvage. In any given section, clean-up would normally start at the highest part of the compartment or tank and proceed downwards to the bilge. The following general principles have been developed from previous efforts: • deal with the large concentrations of oil and hazardous materials early in the operation; • keep compartments clean and make concerted efforts to avoid spillage during salvage and

clean-up;

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• consider removing, instead of cleaning, heavily contaminated machinery and piping (subject to contract obligations). Removal is typically far quicker and allows for less overall effort in clean-up;

• maintain a strong project management presence at the site. 2.2 Security During Clean-Up Security issues that should be addressed include: • Public Safety. A ship undergoing salvage and clean-up operations is a dangerous site.

The public must be prevented from accidentally or casually accessing the interior of the ship and the clean-up site.

• Salvage Security. This is closely linked to the public safety issue. Some members of the

public may actively seek to gain illegal entrance to the site and ship. This security issue requires constant vigilance and repeated assessment. If inadequately secured, a ship may be subject to vandalism and to the theft of valuable components, which may compromise the sale contract. It is highly recommended that a secure lock-up (for tools, valuable salvage items, items that are potentially hazardous, etc.) be made available.

• Ship Safety. A ship will typically have very poor watertight subdivisions within the hull-

form after salvage and clean-up starts. Watertight integrity of the underwater hull may also be marginal in an old ship. Where possible, consideration should given to fitting the ship with flood sensors that have highly visible and audible alarms.

• Environmental Liability. Some of the material removed from the ship could become a

significant environmental liability if it were to be mishandled, disturbed or spilled. Material should not be allowed to accumulate at the site. During the clean up planning process, arrangements could be made in advance to ensure wastes are managed in an environmentally sound manner. Personnel involved in clean-up and salvage operations should be aware of environmental due diligence responsibilities.

2.3 Prepare for Inspections Some states, or sales contracts, may require inspections prior to a ships final voyage, therefore, clean-up operations may need to allow sufficient time for inspections. The ship owner or operator should ensure that the responsible personnel for the clean-up and salvage are on-site for any inspection. As well, access throughout the ship and personnel safety should be considered. 3. GENERAL NOTES ON SALVAGE A notable portion of most ships is normally economically salvageable. Removing usable machinery or equipment that may have hazardous materials (lube oils, solvents) would reduce the hazardous material remaining on board. The sale contract with the ship recycler, however, may require certain components remain onboard. Items that have been salvaged and sold intact include diesel generators and associated equipment, electric motors, various types of lockers, anchors and chain, valves, watertight hatches and doors, furniture, galley equipment and spare parts holdings. Fuel and oil stocks remaining on the ship may have salvage value.

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4. NOTES ON SHIP STABILITY DURING CLEAN-UP AND TRANSITS Operations associated with salvage and clean-up have the potential to adversely impact ship stability. This can be an important issue, especially if the ship has to be moved to its final recycling location. Issues that need to be considered during the planning phase can include: • Weight Removal. Weight removal will impact on the centre of gravity, and hence the

stability, of the ship. In general terms, weight removed low in the ship (ballast bars, bilge piping, etc.) has an adverse impact on stability while weight removed high in the ship has a positive impact on stability. If proponents decide to remove all or most machinery (rather than cleaning it), then a stability check should be undertaken by qualified personnel in accordance with local maritime regulations.

• Mooring. Mooring a ship during clean-up or prior to recycling exposes the ship to greater

risks than would be typically be encountered alongside a jetty. Ships will be subject to wind or wave induced roll, and low hull openings present a flooding hazard. Single point moorings allow the ship to head into the wind, which often minimizes weather effects. If multi-point moorings are established that restrain the ship from swinging on her mooring, then the effects of weather on the ship may be exaggerated. Rolling or pitching could be significantly increased. Ship owners or operators should consider the requirement for temporary pumping capability.

• Watertight Integrity. Internal watertight integrity may not be at initial design standards at

the time of ship recycling, and is often further compromised by salvage activity. • Free Surface Effects. Free surface may be an issue if fluids are allowed to accumulate in

bilges, or if tanks are kept in a partially full condition. The stability of the ship should be considered as an integral part of the salvage and clean-up plan. The ship owner or operator must be continuously aware of ship stability conditions. 6. TANK CLEANING It is acknowledged that fuel tanks would not be cleaned in a ship that is to be delivered to the recycling yard under its own power, thus requiring fuel to operate. The minimum amount of fuel should be used to reduce the need to manage excess fuel on arrival at the recycling yard. Cleaning tanks that would not be used on the final voyage, however, should be considered (cargo, spare fuel, ballast, wastes). There are several accepted and widely used methods to clean fuel and oil tanks. The best method to use will depend on the type of hydrocarbon in the tank, the amount of residue in the tank, and the extent of any hard or persistent deposits and residues. In general, lower quality fuels and heavy oils will require more cleaning effort. Similarly, tanks for dirty or water-contaminated oils will require more cleaning effort. When cleaning tanks, the factors that need to be considered are the Standard requirements, access and safety issues, the machinery and resources available, and the method or facilities available to deal with cleaning residues. It may be necessary to experiment with several cleaning methods to find one that will work in the particular circumstances. Where cleaning is expected to be

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complex or difficult, the ship�s owner or operator should consider securing the services of a professional tank-cleaning contractor. Cleaning double-bottom tanks must be carefully assessed, as there are typically very difficult access and safety issues to be overcome. Options for cleaning tanks include: • Mechanical Cleaning. Mechanical cleaning involves mechanical removal of sludge and

remaining fluids and wiping down all surfaces with oil absorbent material. Although costly in terms of manpower, it does limit the spread of contamination and minimize production of fluids that are expensive to dispose of.

• Steam or Hot Water Washing. This method is quite effective, although it requires special

equipment and generates large volumes of oily water. If this method is contemplated the organization should have a plan to deal with the oily water that complies with local regulations. Surfactants (or soaps) are not recommended, as they tend to emulsify any oil present and make the oily water exceptionally difficult to treat. This would likely drive disposal costs higher than necessary. In tanks where deckheads and sides are reasonably free of contamination, pressure washing can cause significant contamination of these otherwise clean surfaces through splashing, misting, and carry-over.

• Solvent Washing. Solvent washing may be an option where exceptionally tenacious

deposits or films are encountered. Note that the used solvent will require subsequent removal and all of the liquid product generated will require special handling and disposal. In isolated cases, especially where low grade fuels have been stored, it may be necessary to resort to more advanced tank cleaning methods such as ultrasonic or special solvents.

It may be advantageous to employ all three methods in any given ship, depending on the nature and location of the contamination. In general, mechanical cleaning would be the first method to try, followed by steam/hot water washing, then solvent washing in exceptionally difficult cleaning situations. Whichever method is employed, the effluent and waste must be collected and treated. Large volumes will require the services of a pumper truck or barge while smaller quantities may be handled in barrels. Care must be exercised in transfer operations to avoid spills. If large quantities of oil or oil-contaminated liquids are to be transferred the use of a boom around the ship should be considered. 7. CLEANING COMPARTMENTS WITH BILGES Cleaning bilges is frequently complicated by poor access caused by piping, gratings, and equipment. During the planning phase the clean-up contractor should consider the access issue carefully. In many cases it is cheaper and easier to remove interference items (especially when they themselves are dirty or contaminated) than it is to attempt to clean the items and the adjacent bilge. Bilges, once clean, are very vulnerable to recontamination. Ship owner or operators should be aware of the following types of situations, which have given problems in the past.

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• Piping, valves and fittings in hydrocarbon systems will continue to weep for some time after initial draining. These drips can - over a quite short period of time - lead to a significant rework effort. Drips should be captured whenever possible and practical.

• Containers used for clean-up are vulnerable to tipping, especially in the uncertain footing

and poor lighting conditions often found in ships. Buckets should be removed as they are used, or if they are employed for catching drips, emptied regularly.

• Water should not be allowed to enter bilges unless it is part of a planned clean-up

campaign. Water generally complicates clean-up of bilges as the water must be handled as oily wastewater.

In general, the approach and methods for cleaning bilges is the same as for cleaning tanks. 8. DEALING WITH PIPING AND FITTINGS Ship owner or operators should identify those pipes and fittings that contain fuels, oils and oily water as part of the planning activity. If ship�s drawings are not available it may be necessary to develop this information on site. 9. CLEANING FITTED MACHINERY NOTE: Any cleaning of fitted machinery would need to bear in mind if the ship will be delivered to the recycling yard as an operating ship and key machinery components would be required to remain in functional condition. Other machinery components may not be required for the final voyage and could be considered for clean-up here. Cleaning fitted machinery is a lengthy and difficult process. Whenever possible, and subject to sale contract restrictions, consideration should be given to removing and selling fitted machinery. Special attention to ship stability would need to be considered. The general approach to cleaning diesel engines, generators, gearboxes, compressors and other equipment is similar. The clean-up plan should identify the fluids and other contaminants in the machine to be removed. Care should be exercised to capture fluids to avoid further clean-up effort. Fluid types should not be mixed, as this may increase disposal costs and reduce any potential opportunity for their recycling. Large reservoirs of fluids should be drained first, followed by smaller accumulations in machinery housings, piping, and fittings. Gravity will assist in collecting the fluids over a period of time, and the clean-up plan should allow for an adequate drainage period. The precise period required will vary with internal machinery clearances, length and size of piping, fluid viscosity and temperature. As weeping of oils and fuels will continue for several days or weeks, clean-up plans should recognize the requirement to catch the seepage during this period so as to minimize collateral contamination of bilges, decks, piping bundles, and other components. General guidance for specific equipment follows.

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9.1 Combustion Engines • External Oil System. Drain the sump. Identify all external oil lines, coolers and other

fittings. Open and drain these items. After draining, consideration should be given to removing these items from the ship to prevent oil weeping from connections. Remove all oil filter and strainer elements, pressure gauges and gauge lines.

• Fuel System. Remove fuel injectors. Identify all external fuel pressure lines, return lines

and fittings. Open and drain these items. After draining, consideration should be given to removing these items from the ship to prevent fuel weeping from connections. Remove all fuel filters and strainers, pressure gauges and gauge lines. Open and drain any governors.

• Engine Internals. Open all explosion doors, hand-hole doors, maintenance access panels,

etc. On some engines it may be desirable to cut further access openings. Remove heads and clean thoroughly, or drain and remove from ship�note that heads may have salvage value depending on engine type and condition. Open all internal oil lines and galleries; these are designed to maintain integrity of the lubricating system while in service, and will likely be very difficult to remove. Remove oil pump or open it and clean it for inspection. Open bearing pedestals and clean. Open turbo charger or supercharger bearings. At this point it is generally desirable to cut open the main oil sump for better access. Wipe out internal surfaces of engine. Persistent weeping indicates an oil or fuel accumulation that requires investigation. It is generally faster to take an aggressive approach with respect to opening machinery, remembering that reassembly is not required.

• Cooling System. Drain all treated water. 9.2 Gearboxes Gearboxes may be stand-alone items of equipment or integrated into a piece of machinery. The feature in common is a lubricating oil system. Treat initially as for �external oil system� covered under combustion engines. Open all covers and access panels. It may be necessary to cut further access holes to allow for the interior of the gearbox to be adequately cleaned. Open all internal oil lines; these are designed to maintain integrity of the lubricating system while in service, and will likely be very difficult to remove. Open bearing pedestals (especially those in a horizontal plane) if there are oil accumulation pockets.. Remove or drain gearing sprayers. Wipe down all surfaces. 9.3 Other Machinery Other machinery, often termed auxiliary machinery, can be considered in two broad classifications for clean-up purposes. The first group is machinery that does not employ oil lubrication, and does not contain grease other than within sealed rolling element bearings. These machines do not generally require hydrocarbon clean-up unless they were employed pumping fuel or oil, or have large grease reservoirs. Typical pieces of machinery that would usually not require clean-up include small water pumps and ventilation fans.

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The second broad classification of machinery is equipment that utilizes lubricating oil, or contains greases outside of sealed bearings. While auxiliary machinery (air compressors, refrigerant compressors, circulating pumps, steam turbines, etc.) varies considerably in purpose and construction detail, the individual pieces can be dealt with in a similar manner during clean-up. Any working fluids that are hydrocarbon-based or otherwise hazardous should be removed first, and the pump-end left open. Fitted lubricating oil systems should be cleaned as noted under the heading �external oil system� in the combustion engine section. If a gearbox is fitted, treat it as for the section on gearboxes. Experience indicates that oil sumps in small pieces of machinery will almost always need to be cut open to allow adequate access for cleaning. Wipe down all internal oiled surfaces. Grease packed couplings, stuffing boxes, chain sprockets, worm drives, etc. must generally be opened, unless they meet the restrictive �small quantities� exemption in the Standard. The grease is usually best removed by mechanical means, although in some cases of very limited access (such as gun rings), it may be necessary to resort to steam or solvent washing. Basic knowledge of machines and an understanding of the purpose of the specific equipment typically allow the clean-up effort to proceed more efficiently. 10. SUGGESTIONS ON HANDLING WASTE Salvage and clean-up operations will generate a large quantity of material that needs to be removed from the ship. Hazardous material must be carefully segregated from the normal waste stream to avoid contaminating the normal stream, thus incurring larger costs to dispose of the whole amount as hazardous material. Liquid waste presents special handling problems for clean-up crews. Recovered oils and fuels may be employed for site or ship heating purposes if suitable, but other liquids may typically need to be processed through hazardous waste contractors. To minimize disposal costs, waste liquids should not be mixed and containers should be labelled with all available information on the product. Liquid storage and movement around the site must be tightly controlled. Control of run-off from temporary storage sites should be addressed in the pollution prevention plan. A covered area with an impermeable floor and berm is highly recommended and may be required by local authorities. An area will need to set aside for oil and fuel pipes, fittings, and other components to drain. This must be done in a covered area and is often best accomplished in a compartment in the ship set aside for this purpose. Solid wastes that should be addressed include disposal of used oil absorbent materials, asbestos and non-asbestos insulation.]

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